Haugen v. United States

Issue: Whether the court should grant certiorari to resolve the circuit split between the U.S. Court of Appeals for the 8th Circuit's decision in United States v. Carlson holding that the petitioner was not denied a fair trial based on the inferential United States v. Turcotte instruction allowing the jury to find the petitioner guilty beyond a reasonable doubt under both prongs of the two pronged test for conspiracy to distribute controlled substance analogues based upon proof beyond a reasonable doubt based solely on the second prong, and the 10th Circuit's decision in United States v. Makkar, where the court held that the Turcotte instruction does not allow a jury to find the first prong of the above test proven beyond a reasonable doubt based exclusively on proof beyond a reasonable doubt of the second prong of the test.